WeWork4Water Blog

Archive

Wednesday, July 8, 2015

As the drought in California drags on, the State of California as well as water companies are searching for ways to convince people to continue to conserve that don’t involve simply raising rates or imposing draconian fines and penalties. One way to do that may be the implementation of trading water credits at the consumer level.

Currently, California residents are staring water allocations in the face based on their 2013 usage. Depending upon how much they and their neighbors have used in the past on a per capita basis, they could be looking at having to cut back anywhere from 4% to 36% from those 2013 numbers. But what if I have an easier time conserving than my neighbor and reduce my water use by more than required. Or what if my household in 2013 consisted of me, my wife, and three teenagers who seemed to live half their life in the shower and who have now gone off to college, meaning my water use has already fallen off a cliff, even if my tuition bills haven’t. If I cut back a whopping 50% based on my 2013 water usage, all I’m likely to get for it is a lower water bill – maybe. Not even an “Atta boy!” from the water company or Governor Brown. That’s not a great incentive to do more than I absolutely, positively have to, and in fact might be a negative incentive to make sure I don’t do more than required. And for businesses, forced conservation could result in a decline in revenues and loss of market share, while not conserving could result in tremendous additional costs that eat away at already meager profits. A definite lose – lose.

So what’s the answer? I’m sure there is more than one, but it could be that allowing individual water consumers to participate in water credit trading on a limited basis could drive conservation to levels not even seen in the wildest dreams of Felicia “Lawn Terminator” Marcus. How might that work? Say, with my three teenagers safely off at school, my wife and I use 5,000 gallons per month less than our allocation. We should be able to “sell” the right to use that water to another individual or business. That individual or business could then buy those 5,000 gallons from the water company at the normal rate plus a small fee, without any additional penalties even if it were above their allocation. I, in turn, would get a credit on my next bill equal to that small fee paid by the user. If you really wanted to go all free market, you could even let the level of that fee float and be determined by what the market would bear.

Granted this is an over-simplification, and many of you will point out flaws, not the least of which is that it’s a complicated structure for the water company to keep track of. So now instead of hearing about the flaws, how about we hear from some of you on how to make it work. Or let’s hear about your completely out of the box ideas on how to drive conservation. There really are no wrong answers, only starting points.

Also included would be any extremely hazardous substance
over its threshold planning quantity as described in 40 CFR, Part 355, AppendixA. This last list would not be as
applicable to water related businesses, except that it does include
chlorine. So if you use chlorine gas
that would certainly apply to you.

So what is a hazardous material? The California Health and Safety Code lists a
hazardous material as anything that, “because of its quantity, concentration,
or physical or chemical characteristics, poses a significant present or
potential hazard to human health and safety or to the environment if released
into the workplace or the environment, or a material specified in an
ordinance.” That’s a pretty all
encompassing definition that could make anything hazardous. Thankfully, there are some more definitive
lists that you can turn to such as:

a hazardous waste, which will be the topic of
another blog post, so stay tuned for that!

An HMBP is the document which contains detailed information
on the storage of those hazardous materials.
One is required for each location where hazardous materials are
stored. If a business has multiple
locations where hazardous materials in excess of the storage limits listed
above are stored or used, then a separate HMBP must be completed for each of
those sites. The HMBP must contain:

Business Activities – this section details what
activities are engaged in at the site that involves hazardous materials.

Business Owner / Operator Identification –
identifies the owner/operator of the facility along with emergency contact
information.

Hazardous Materials Inventory – a one page
document required for each hazardous material stored at that individual
location.

Site Map – A map of the site showing
specifically where the hazardous materials are stored, including:

the outline of any buildings

site orientation (North arrow)

loading areas and parking lots

internal roads

storm and sewer drains

adjacent property uses

adjacent streets, alleys, or other access

access and egress points

evacuation routes

staging areas

fire hydrants.

fire extinguishers

emergency shut-down systems for electrical
and other equipment

the storage location for the HMBP

Emergency Response Plan – includes the action to
take in case of emergency; local utility information; local medical provider
information; emergency equipment available on-site; and emergency contact
information.

Employee Training Plan – describes the training
provided to facility personel to make them aware of the hazardous materials
being stored and used on-site, as well as the training provided for emergency
response.

Other documents may also be included depending
upon the type of material being stored, such as if you have underground fuel
storage tanks.

An HMBP must be updated within 30 days of any changes being
made to any of the information contained in the various sections. An annual certification must also be made
that the HMBP is current and up to date.
These certification can be made through the CERS website, or you local
CUPAs electronic portal.

There is a great deal of valuable information contained in a
hazardous materials business plan that can help prevent hazardous materials
releases or mitigate their impacts, as well as being of help to first
responders on the scene of an emergency at a facility that stores hazardous
materials. But like anything else, they
are only any good if the information they contain is up to date and
accurate. If you need any help with
HMBPs or dealing with hazardous materials in general, please contact me at Patrick.vowell@wework4water.com,
and I’d be happy to help.

Tuesday, September 23, 2014

Any business that has to handle and store hazardous materials has a responsibility to make sure they are doing so responsibly and in a way that meets all current regulations. For those that store above certainthresholds of hazardous materials, that includes having a Hazardous Materials Business Plan (HMBP) and submitting it to your regulator. In California that requires using an electronic submittal portal, either one supplied by the individual CUPA in some cases, but in most cases, it means the California Environmental Reporting System, or CERS.

What is CERS? “The California Environmental Reporting System (CERS) is a statewide web-based system to support California Unified Program Agencies (CUPAs) and Participating Agencies (PAs) in electronically collecting and reporting various hazardous materials-related data as mandated by the California Health and Safety Code and new 2008 legislation (AB 2286). Under oversight by Cal/EPA, CUPAs implement Unified Program mandates that streamline and provide consistent regulatory activities.” (CERS Central website) Yikes. In much simpler terms that even I can understand, CERS is an electronic submittal program that allows businesses to submit their HMBPs and some other environmental reporting documents, and keep those submittals updated or certify annually that there have been no changes.

Submittals to CERS include hazardous materials business plans, chemical inventories, site maps, underground and aboveground tank data, and hazardous waste related data. Any business that is regulated by a CUPA and needs to submit such documents must do so electronically using CERS or the individual CUPA reporting portal if they have one. Paper forms cannot be submitted. The local CUPA reporting portals and CERS are supposed to communicate and swap data, but that aspect of the program still has some issues. Your local CUPA is not supposed to require you to submit to their local reporting tool rather than CERS, but you might find that has issues as well.

If you’ve never used CERS before, it’s really not very hard. There are lots of training resources available on the website, and if you still have questions, I’d be more than happy to help. You can contact me via my WeWork4Water website, LinkedIn, or e-mail me at patrick.vowell@wework4water.com .

Wednesday, August 27, 2014

Hazardous materials management and hazardous waste
management in California can be an undertaking that spans multiple regulatory
authorities across many levels of government, making it a daunting task. The
California Environmental Protection Agency (Cal/EPA) seeks to simplifyy that
process a bit by consolidating many of those functions under the umbrella of
the Certified Unified Program Agencies (CUPA).

CUPAs are usually a county or city health department or fire
department that has gone through the process of applying to and being approved
by Cal/EPA for status as the CUPA. These
local government agencies are responsible for implementing the standards set by
the state agencies responsible for the following six programs:

One of the
big benefits of this program is the need for only one permit to cover any and
all of these programs, rather than having to track multiple permits. Other benefits come from having one agency
doing inspections, rather than multiple agencies that may have mutually
exclusive perspectives for a given requirement; a single fee structure, which
should end up being less expensive theoretically; and the need to only submit
forms and other information one time to one agency, rather than submitting the
same information to multiple entities.

Tuesday, July 15, 2014

California,
always striving to be at the forefront of just about everything, is now the
first state in the US to implement a drinking water regulation for hexavalent
chromium, or chrome 6. Even though the
regulation remains hotly contested, it is now the law. So what does that
mean to water quality professionals and operators in the field? Let’s take a look at the regulation and see.

The new regulation went into effect on July 1, 2014. That’s
the same day that responsibility for the drinking water program in the state
transferred from the California Department of Public Health (CDPH) to the State
Water Resources Control Board Division of Drinking Water (DDW). CDPH sent out a
letter on June 20 that had a good overview of the regulation. You can get a copy of the most recently updated drinking water related
regulations from the still functioning CDPH website, or you can download a copy of it here. Chrome 6, or hexavalent chromium as they have
it listed, is included with the other regulated inorganic contaminants starting
at the bottom of page 109. The approved
method for analysis is EPA Method 218.6 or 218.7, and a list of laboratories approved to run these methods as of May 22, 2014
is available here. Make
sure you call and talk to whatever lab you chose just to make sure they are
currently certified and what their sample submission guidelines are.Although the regulation takes effect July 1, §64432(b) states
“…each community and nontransient-noncommunity water system shall initiate
monitoring for an inorganic chemical within six months following the effective
date of the regulation…”, so you have until the end of the year to take your
initial sample. If you've already taken samples, §64432(b)(1) allows you to use
data collected in the previous two years as your initial sampling, so chrome 6
data from July 1, 2012 thru June 30, 2014 can be used if you so desire. You
would just have to go back and ask your lab to upload it to the state database to
make sure it’s been entered as compliance data.
You would also need to make sure the samples had been analyzed using one
of the appropriate methods, because if they weren't they won’t be acceptable as
compliance data.Alternately, §64432(b)(2)
of the regulation allows you to use total chromium data in lieu of chrome 6
data if your total chromium results are below the total chrome detection limit
for purposes of reporting (DLR) of 0.010 mg/L.
The logic there is since chrome 6 is included as a part of the total
chromium analysis, if total chrome is below 0.010 mg/L, then chrome 6 must be
as well.Technically, the regulation
should allow you to collect samples at the source or at the entry point to the
distribution system. §64432(e) states “Samples
shall be collected from each water source or a supplier may collect a minimum
of one sample at every entry point to the distribution system which is
representative of each source after treatment.” However, regulators seem to be interpreting that to mean the sample must be taken at the source. It’s a good idea to discuss
with your local DDW office where your compliance sampling point needs to be, and be
sure to sample from the same location every time.Like most inorganics, the initial monitoring will determine
your subsequent monitoring schedule. §64432(j)
states, “If a system using groundwater has collected a minimum of two quarterly
samples or a system using approved surface water has collected a minimum of
four quarterly samples and the sample results have been below the MCL, the
system may apply to the Department for a reduction in monitoring frequency.” Compliance with the MCL will be determined on
a running annual average (RAA) of 4 quarters of data. If you take more than one sample per quarter,
the average of the samples for that quarter will be used in calculating the RAA.There is a provision in the regulation (§64432(f) on the
bottom of page 112) for any inorganic contaminant that allows you to composite
up to 5 wells. However, you have to get approval from CDPH for such a plan, and
it is based in part on 3 years of historical data. I’m guessing that with the political nature
of chrome 6, the newly minted DDW may not want to venture down this road.So what are the options if you have wells over the MCL? There
are various forms of treatment, which of course are all very costly. Best
available technologies (BAT) for chrome 6 are coagulation/filtration; ion
exchange; or reverse osmosis. All of
these have quite high capital and operational expenses. I think systems with a
mix of wells, some over the MCL and some under, need to look long and hard at
blending. If you’re wells are scattered that means installing dedicated
transmission mains, which is costly and disruptive. But I think when you do a
cost analysis on how much treatment is going to cost, looking at both capital
and operations, you might find that installing transmissions mains, even long
ones, to facilitate blending doesn't look so bad.That’s a
general overview of the new regulation, and a synopsis of compliance issues to
be aware of. If you have any other questions, don’t hesitate to reach out to me
and ask. You can always contact me via LinkedIn or e-mail at patrick.vowell@wework4water.com.

Tuesday, July 8, 2014

This is a message from the State Water Resources Control Board.

This message is to notify interested parties of the availability of the attached Proposed Emergency Regulations pertaining to the Prohibition of Activities and Mandatory Actions During the Drought Emergency; Notice of Proposed Emergency Rulemaking; Emergency Regulations Digest; and Fact Sheet.

This item will be considered at the July 15, 2014 State Water Board meeting. The State Water Board is particularly interested in hearing comments on the applicability of the proposed regulations to wholesale water suppliers, as well as comments pertaining to other aspects of the proposed regulations.

Friday, July 4, 2014

Advanced oxidation processes are becoming more prevalent in wastewater,
recycled water, and drinking water treatment. There is no doubt that these
processes are very effective at treating a wide range of otherwise difficult to
treat for chemicals from whatever source you start with. But what happens to
the chemicals we are treating for when we use advanced oxidation? And could we be
creating a bigger problem than we started with?

Advanced oxidation (AO) refers to treatment to remove chemicals by
oxidation through reactions with hydroxyl radicals. Most commonly, this is achieved by the
addition of either ozone (O3) or hydrogen peroxide (H2O2) and then exposure to UV
light. The process is very effective; if
you have a given chemical in your source and then treat it by an AO process and
re-test it, the chemical will be found at a greatly reduced level or even be completely
gone. But where did it go? This is not an adsorptive process like ion
exchange or treatment with GAC; the chemical is not being physically removed
from the water. The Law of Conservation of Mass,
as well as common sense, dictates that it cannot simply disappear. And AO
treatment does not break chemicals down all the way to their individual atomic
constituents. So what’s really happening?

The AO process simply changes the chemical into something else. Usually, a chemical is broken down into
smaller chemicals, although that is not always the case. Sometimes its form is simply modified. So what you end up with after advanced
oxidation is not contaminant free water.
You have simply traded one contaminant for one or more others. That is the point at which I start to worry
about the AO process. To oversimplify,
the AO process takes one contaminant that we may or may not understand the toxicity
of, and modifies it into one or more different contaminants that we probably
know even less about.

Some research has been done on this issue, but not nearly enough. One group of researchers show how the cancer
drug cyclophosphamide (1), when treated by AO, has as its main reaction product
4-ketocyclophosphamide. You can see from
the chemical structures in Figure 1 that the reaction product is not much
changed from the parent compound.

If you analyzed your water after treatment, it would appear the
cyclophosphamide had gone, which it has, but only to be replaced by a very
similar compound. Is that good? Is the
water after treatment more protective of the environment and of public health? I don’t think we have any idea, which is
exactly the point.

Another excellent paper that came out in 2007 in The Journal of the International Ozone Association (2) reviews the
knowledge of a wide range of compounds and how they react in the AO process. In
the paper, the authors state “In some cases, disappearance of parent
pharmaceutical compounds does not indicate successful treatment because the
degraded products may be as biologically active as the parent compounds.” The degraded products may be as biologically
active as the parent compounds. Or they
may not. Or we may have absolutely no
idea if they are or not, so we may have no idea whether what we are considering
treatment isn’t itself a source of contamination.

In
the same paper, one of the compounds reviewed is carbamazepine, a widely used
anticonvulsant that “has been found ubiquitously in the aquatic environment.” The reaction products of carbamazepine after
AO are several, and have names far too long for me to type out here. But the
authors recognized that these reaction products were “polycyclic
heteroaromatics known to be toxic to aquatic organisms.” Are they more or less toxic than the
carbemazapine itself? Do they have synergistic effects that cause them to be
more toxic working together than separately? Again, we just don’t know.

Just this year, a paper was published describing a new tool that is
available to try and answer the question of how compounds break down when
subjected to AO. In the ACS Journal Environmental
Science & Technology, Xin Guo, et al (3) gives the basis for a model that
can be used to “predict the degradation mechanisms and fates of intermediates
and byproducts produced during aqueous-phase advanced oxidation processes for
various organic compounds.” That’s
sounds like a great tool that those who implement these processes should look
into to help predict what’s actually happening during treatment.

AO is a promising technique that has proven applications in many water
treatment scenarios, whether you’re dealing with wastewater, drinking water, or
water recycling. But a great deal more
study needs to be done to make sure we aren’t creating bigger problems than we
currently have. I call upon all of those
involved in the issue, manufacturers, end users, and industry associations like
AWWA,WRF, and WEF, to support the investment needed for research into these questions.

About Me

Patrick Vowell currently works as a Water Quality Engineer for an investor owned drinking water utility in San Luis Obispo, Santa Barbara, and Ventura Counties in California. This involves working with 9 drinking water systems ranging in size from a population served of 200 to more than 40,000. The position is responsible for ensuring compliance with all state and federal drinking water regulations, as well as environmental compliance for NPDES permits; air quality permits; hazardous materials, hazardous waste management; CEQA; and other regulations and environmental permitting.
Patrick’s experience includes 10 years working in analytical laboratories in positions ranging from bench level chemist to laboratory director, and includes 5 years of experience in GC/MS, as well as experience in GC/MS/MS and LC/MS/MS.
Specialties include
Water Quality Monitoring & Treatment Recommendations; Environmental & Other Regulatory Compliance; Project Management and Team Leadership.